Facts
- After the 2020 census, the North Carolina General Assembly enacted a new congressional redistricting plan.
- North Carolina voters and public-interest groups challenged the plan as an unconstitutional partisan gerrymander under the North Carolina Constitution.
- A state trial court held partisan-gerrymandering claims nonjusticiable under the state constitution.
- The North Carolina Supreme Court reversed, held the claims justiciable, invalidated the map, and ordered remedial proceedings.
- Legislative leaders petitioned for review, arguing the Elections Clause gives state legislatures exclusive authority over rules for federal congressional elections, limiting state-court power to invalidate or replace those rules.
- While review was pending, the North Carolina Supreme Court granted rehearing in related proceedings, withdrew a later remedial-map opinion, overruled its earlier decision, and dismissed the challenges.
- The U.S. Supreme Court concluded the dispute was not moot and proceeded to decide the federal constitutional question.
Issues
- Whether the Elections Clause vests state legislatures with exclusive, independent authority to regulate federal congressional elections free from constraints imposed by state constitutions and state judicial review.
- Whether, and to what extent, state courts may enforce state constitutional limits against a legislature’s rules governing federal elections without violating the Elections Clause.
- Whether intervening state-court proceedings eliminating the prior state-court merits ruling rendered the case moot.
Decision
- The Court affirmed the judgment under review in a 6–3 decision authored by Chief Justice Roberts.
- The Court held that the Elections Clause does not give state legislatures exclusive, independent power over federal election rules.
- The Court held that state legislatures remain subject to ordinary constraints of state constitutional law, including state judicial review.
- The Court stated that state courts do not have “free rein” to displace legislative choices; extreme departures from state law may present a federal question.
- The Court rejected mootness and reached the merits despite the intervening state-court reversal.
Legal Principles
- The Elections Clause’s reference to “the Legislature” denotes the state’s lawmaking function as structured by the state constitution, not a body exempt from state constitutional limits.
- State courts may review and invalidate state laws regulating federal elections for compliance with the state constitution in the ordinary course of judicial review.
- Federal courts may review state-court decisions in this area when a state court’s interpretation or remedy constitutes a significant departure from, or is not grounded in, state law in a manner that implicates federal constitutional limits.
- Intervening state-court developments do not necessarily moot a federal Elections Clause dispute when the challenged judgment and its legal consequences remain live for the parties.
Conclusion
The Court held that the Elections Clause does not insulate state legislatures from state constitutional constraints or state-court judicial review when regulating federal elections, while recognizing that state courts remain subject to federal limits if they depart sharply from state law in a way that effectively displaces the legislature’s assigned role.